Dr Sandy Gerrard, joint discoverer of the Mynydd y Betws Stone Row and critic of the archaeological procedure surrounding the development of the Mynydd y Betws wind farm has made a detailed response to the Preliminary Statement on a Stone Alignment supplied by Cotswold Archaeology (who were retained by the developers to carry out all the post planning permission work including, once it had been discovered, the excavation and a detailed, non-intrusive characterisation of the stone row). The report is lent great significance by the fact both Cadw and the Heritage Minister have indicated that they may base their future management of the site on it.

For the record and for the use of those that wish to follow the full details of this ongoing matter, the whole of Sandy’s comments are reproduced below. For those that prefer a summary we recommend reading his “Introduction”, “Conclusion” and “Summary of Evidence” as a minimum. In the former he opines that the report is “subjective, poorly written and makes no attempt to present all the available evidence and various interpretations in an unbiased academically rigorous manner” and that the pros for the alignment not being prehistoric are “desperately explored and emphasised whilst the cons are ignored”. This view appears to be greatly reinforced by the Summary of Evidence which points very strongly to a prehistoric origin. His central charge relating to the Report therefore is one of “very poor scholarship” and in addition he lays out how the archaeological project as a whole should be seen as “a system which is clearly unfit for purpose”.

I have been sent a draft copy of the statement by Dyfed Archaeological Trust and invited by Cadw to comment on the contents. The report clearly illustrates that both Dyfed Archaeological Trust and Cadw have already contributed to it. I have sent copies of my response to Dyfed Archaeological Trust, Cadw my local MP and Assembly Member. I believe these comments provide balance to this important debate which needs to be conducted in public as these are matters that affect us all.

This report in my opinion is subjective, poorly written and makes no attempt to present all the available evidence and various interpretations in an unbiased academically rigorous manner. When considering the prehistoric interpretation for the alignment, only the issues which the authors consider to detract from this explanation are explored whilst the numerous reasons to accept the possibility of the hypothesis are not even mentioned. By marked contrast, when it comes to the alternative explanations only the pros are desperately explored and emphasised whilst the cons are ignored. It is clear that all available sources have not been consulted. The failure to consider the known impact of solifluction on alignments and the absence of any excavation photographs and drawings truly indicates the superficial and inadequate nature of the report. This is an example of very poor scholarship and any decisions that rely on this report will inevitably be questionable. At three points the excuse of thick vegetation is trotted out for the alignment not being identified during the lengthy planning process. No evidence is presented to support this position which looks increasingly ridiculous as all bodies involved admit that no field survey was carried out at any stage. Surely it is time to admit that mistakes were made and commit to changing a system which is clearly unfit for purpose. The very notion that archaeologists are content to allow development of uplands rich in earthworks without first conducting a final search to identify previously unrecorded remains is absurd on so many levels and cannot be justified. In this case, the situation was made so much worse by the fact that the planning inspector had already pointed out in his report that there was unrecorded visible archaeology, however even this was not enough to precipitate a final check. The discovery of archaeology during the development process was therefore sadly inevitable. Worse still is the possibility that this important landscape might have been safeguarded entirely had its full archaeological significance been recognised earlier.

Detailed commentary [NB – Quotes from the report are in blue.]

1.1 It is usual practise to credit those responsible for identifying sites. This report simply notes that the “stone alignment has recently been discovered”. This churlish start sets the tone for the rest of the report which is clearly intended to minimize the potential significance of the alignment.

The vegetation on the moor is regularly burnt and the text implies that the monument was discovered because of the most recent fire. Photographs taken of this hillside in 2005,2009 and 2011 clearly show relatively sparse vegetation. At no point have those who claim that the hillside was covered in dense vegetation provided any evidence to support this increasingly untenable position.

The report uses the term “detailed archaeological investigations” to describe the work that was conducted. There is however, no detail within the report indicating what this actually means. No specific statement of the methodology employed is included nor are any photographs or drawings of the excavations provided to allow independent scrutiny of the evidence and how it was collected. There is nothing within this report to support the contention that any detailed investigation was conducted. Very little information or evidence is supplied and indeed many of the omissions highlighted below could support the contention that only a superficial and perfunctory investigation has actually been conducted at all.

The report claims the detailed investigations were carried out to “determine the extent and nature of the feature”. It is difficult to see how this could be done without carrying out a detailed survey and measurements of the whole length of the alignment. There is no evidence that the alignment was surveyed beyond a few strategic points along its length. Despite these “detailed investigations” the report certainly does not provide much information on its extent and nature. Furthermore they claim to have carried out this work before they were given the wider brief on 27th February.

1.2 A detailed survey of the stone alignment would seem to make an obvious starting point for “a detailed, non-intrusive characterisation of the stone row”. There is no evidence within this report that such a survey has been conducted. It is interesting to note that they are now calling the feature a stone row on occasions.

1.5“During the development of the proposed layout of the wind farm, all known archaeological sites were avoided to prevent direct impact to these remains”. This is blatantly untrue. A small number of sites already recorded within the HER were not avoided. They may have been considered to be of lesser importance, but they are still archaeological sites, were recorded and have now been damaged, in some instances with no record being made.

This paragraph confirms that “no archaeological fieldwork was undertaken during the preparation of the Environmental Statement”. Why was this situation never challenged by Cadw, Dyfed Archaeological Trust or Carmarthenshire County Council?

1.7 The report refers to the outcrop coal workings in the vicinity of the stone alignment as “shallow adit workings”. There is at least one adit associated with these workings but no evidence that it is connected to these surface outcrops. If the adit does form part of these workings it would be very unwise to build turbines in this area. The surface remains strongly suggest the presence of a low capital, labour intensive, small scale and short lived extraction of the outcrop alone and the term adit working would therefore seem inappropriate.

1.12 A short length of the stone alignment is clearly visible on both Google and Bing aerial photographs and it is therefore surprising to read that “no evidence for the stone alignment was revealed on any of the consulted sources.” Why has publically available material not been consulted? These photographs of course provide further evidence that the stone alignment was clearly visible and not wholly obscured by vegetation as claimed.

Examination of aerial photographs for most Dartmoor stone alignments reveals the presence of paths/sheep tracks running alongside them. The presence of the path is a phenomenon one would expect to find alongside a line of stones whatever their origin.

2.1 The stone alignment was visible prior to the most recent burning of vegetation. Google and Bing images clearly show the larger stones with no vegetation cover. Again evidence to support the contention that the alignment was not previously visible has not been provided. The failure of the mitigation strategy to include a field survey element is a much more likely explanation for the previous failure to identify the feature. It has been claimed that this is the most studied hilltop in Wales and as much of this work was carried out in 2011 in the period before the fire surely photographs must be available to demonstrate the precise character of the vegetation that made it impossible to see the archaeology on this hillside.

2.2“The stones are, mainly, laid flat” This wording implies that the stones were originally positioned this way but there is currently no evidence to support this contention. Also what is meant by ‘mainly’? An empiric value or percentage based on the characterisation might have been a more useful indication than the word ‘mainly’. According to this report “detailed investigations” were carried out so precise figures on upright and recumbent stones should be available. The alignment is 700m long and yet the two images presented within the report are both from a short length where the stones are mainly recumbent. Photographs taken at any other point along the length of the alignment would should a row of upright stones. All my reporting has shown varied images so why did the authors of this report decide to include only those from one very short length?

2.3“The land is currently open moorland and there are no direct threats to the integrity of the row.” This is a very bold and inaccurate statement. On the one level it is difficult to see how this area can now be described as open when there are roads with barbed wire fencing either side which makes it impossible to walk the length of the alignment unhindered. The authors also appear to have a rather optimistic view concerning threat. This area has now been developed and access to it much increased. Unprotected the site may become a target for unregulated excavations. Compared with many other wind farms the density of turbines is low and there will undoubtedly be pressures to increase the number of turbines on the hillside in future years. If the alignment is not afforded statutory protection it is very likely that it will be damaged again. Perhaps the authors would prefer to view these as indirect threats, although I prefer to see the erection of turbines in its immediate vicinity as having an impact on its setting. A view that I believe Cadw has already expressed.

2.4 The methodology used for the original evaluation trench (2011) would be very unlikely to reveal anything subtle and it is therefore not surprising that the alignment was not identified. The failure to find it does not mean that it was not there rather it highlights a significant failure in the methodology employed.

2.5 Excavation Report on Area A (access track leading to Turbine 16) The information provided within this report is insufficient to allow an independent review of the excavated evidence. Further information needs to be presented before the findings can be subjected to an appropriately informed review. The pathetically short paragraph supplied as evidence to show the exact nature of the archaeological work undertaken is insufficient for any form of useful assessment to be made as it has no academic value or information.

2.6 Excavation Report on Area B (main access track) As with 2.5 above the information provided within this report is insufficient to allow an independent review of the evidence. Further information needs to be presented before the findings can be subjected to an appropriately informed review. In particular one would normally expect photographs and drawings to be available for scrutiny. As with the above point there is nothing presented which shows any excavation was undertaken at all.

3.1“The term “stone alignment” is usually used to define a specifically prehistoric monument”. The term stone alignment has been used almost exclusively within this report to refer to the feature. Does this mean that the authors secretly believe this is the most likely interpretation after all?

4.1 In this paragraph the report spells out clearly for the first time the explanation for the stone alignment being overlooked. According to the report various bodies failed to find the alignment “due to the thick vegetation obscuring the stones”. Again I would ask for the evidence to support this statement. The evidence available to me which is all publically accessible shows that the alignment was not obscured and that instead surely a more plausible explanation is that no attempt was made by the various bodies mentioned to systematically search the area relying instead on records from earlier years. To make matters worse the planning inspector had previously reported seeing unrecorded archaeology within the development area and still no search was carried out. Until evidence of this thick vegetation is provided it would seem more plausible to accept that the alignment was not identified because no attempt was made to look for visible archaeological remains and instead all of the emphasis was placed on searching for archaeology below the surface or in a database.

4.2“the stone alignment may be interpreted as a part of this prehistoric landscape. Several features of the Mynydd y Betws example, however, are not consistent with this interpretation”“Most strikingly, the stones within the row are of variable size and shape but generally an average size of 0.3 – 0.5m.” Variable size and shape is a feature of the Dartmoor stone rows and many include stones smaller than the average sized stone at Mynydd y Betws. It has been demonstrated that alignments were built using locally available material and therefore in areas where only small stones were available the alignments are composed of small stones. Often the largest stone in an alignment forms a terminal and at Mynydd y Betws the largest stone indeed forms the south western end. The small size of the stones at Mynydd Y Betws is therefore entirely in keeping with the evidence from the south west of England. To dismiss this alignment on the grounds that it is not like others in the area is a dangerous thing to do particularly when there is no evidence to support the contention that it is not prehistoric. Its similarity to SW English examples is the most exciting aspect of the site as it may confirm the presence of social/economic interactions across the Bristol Channel at this time.

“The stones investigated during the evaluation were also only shallowly embedded in the soft natural geological substrate and did not lie within deliberately dug pits/sockets”. The size of any hole dug to receive a stone is necessarily proportionate to the size of the stone being erected. As has been pointed out above the stones are generally small and therefore one would not expect to find large holes dug to receive them. Indeed a small hole cut into the soil which did not penetrate the subsoil would be sufficient to firmly hold stones of this size in place. Prehistoric house and cairn builders would often erect massive stones on the surface without digging holes to receive them instead relying on trig stones. I am not suggesting that this was the case here but the absence of socket holes does not in itself prove that these stones were not erected in the prehistoric period. Indeed when one takes into account the possible complicating effects of solifluction, the absence of socket holes does not detract from the suggested prehistoric date. It is also of interest in this context to note that the 1.2m high Hobajon’s Cross forming part of the sinuous Butterdon Hill stone alignment was found to sit in socket hole measuring a mere 0.15m deep.

“The overall alignment of the Mynydd y Betws alignment is sinuous in form which is not typical for prehistoric ceremonial/ritual stone alignments which are….. predominantly straight” This statement is wholly inaccurate. The briefest look at the alignments on Dartmoor would have revealed to the authors of this report that many (particularly the long ones) are sinuous in character. An explanation that has been offered is that this is the result of solifluction. The Mynydd Y Betws alignment runs at an angle to the contour and therefore it is highly likely that the sinuous nature of this alignment is the result of variable solifluction. This is crucial because rather than detracting from its age, this situation suggests some considerable antiquity. Solifluction does not explain the sinuous nature of some of the Dartmoor rows and instead it must be concluded that local circumstances sometimes resulted in the construction of rows of this form. The argument that the alignment is unlikely to be prehistoric because of its sinuous character is therefore entirely untrue and indeed is actually another factor in favour of the prehistoric interpretation.

None of the objections to the prehistoric explanation can withstand any level of scrutiny and indeed a closer examination of these issues actually enhances the likelihood that this feature is prehistoric in origin. Having considered the reasons why they conclude the alignment is unlikely to be of prehistoric origin, the authors of the report helpfully move on to suggest alternative explanations, being very careful not to subject their own interpretations to same level of scrutiny that they have unsuccessfully attempted on the prehistoric explanation.

4.3“One interpretation may be a former boundary/fence line, as post-medieval and modern fence lines strengthened by small and large stones are known from various localities in Wales (Charles Hill pers. Comm). Over time most of the smaller stones and embanked material can erode away leaving only the larger boulders in their original position” The strengthening of fence lines with stones is an interesting thought. The strength in a fence relies on it being kept straight and taut and generally stones are used only to reinforce the fence by being placed on the ground to prevent livestock escaping under gaps created by uneven ground. The sinuous character of the alignment combined with the failure to find any post holes in two separate interventions would argue against this as an explanation. Solifluction alone within the available timescale would not explain why it was not built along a straight line. One also needs to question how effective an unconnected fence would be in any agricultural context. Furthermore fence lines tend to attract livestock for scratching purposes and the resultant increased traffic adjacent to it generally creates a linear erosion hollow which in a stable moorland environment would survive for some considerable time. There is no evidence for a hollow associated with this feature. Together these details make it very unlikely that the alignment was connected in any way with a fence line.

The reference to “embanked material” seems to be implying that the authors believe that there may have been a bank. Banks are created by the digging and piling of material which leads to the creation of an associated ditch from which this material was derived and as no ditch was found in either excavation area any interpretation which relies on the feature being the extremely eroded remains of a bank is actually discounted by the evidence from the excavations. Given this very clear evidence it is curious that this possibility has even been suggested and interestingly this very obvious contradiction was not explored within the report. Furthermore, the report notes that many of the stones are buried below the soil. This suggests a depositional environment rather than the erosive one implied by this report and indicates that the suggested interpretation is not supported by the field evidence.

4.4“An alternative, although closely related, interpretation is that the stone alignment may act as a waymarker for former pathways and access onto the moorland”. The report then mentions that such a way marked path could have been followed in poor weather including snow. Mention is also made of the nearby path visible on photographs. The report suggests that the path would have provided access from Bryn Mawr farmstead to the “adit workings near the summit”. Ignoring the fact that there are no adits near the summit for the moment it is perhaps worth asking why a huge amount of effort would be expended by the farmers building a marked footpath from their farmstead to a small scale temporary working which by its very nature would have been constantly moving when there were already two trackways leading to the area: one to the north of the alignment and another to the south. It is also perhaps worth asking why none of the other very obvious trackways on the hillside were not similarly marked and perhaps why stones were used which become completely invisible after even moderate snow fall. It seems to be stretching a point to suggest that the low capital venture represented by the outcrop workings would bother to invest considerable time and effort in laying out a path to a part of the mine from which they would have probably moved by the time it was completed. Such an idea is simply not logical and so farfetched as to be seen as either desperate or laughable. The presence of animal paths roughly following alignments and other linear features of any date is a common feature of upland moorland landscapes and implies nothing. It is also worth noting that where paths are built with stone markers the path or track is always established on the upper side of the stones and there is no evidence to suggest that a path or track ever formed in this position. The path which the authors have identified is on the lower side of the alignment and has been therefore almost certainly formed exclusively by animals respecting the adjacent uneven ground. As there is no evidence for a path or track on the upslope side of the alignment this interpretation would seem to be seriously flawed. Perhaps even worse the suggestion that the occupiers of Bryn Mawr farmstead needed a line of stones to help them find their way across a small area of moorland immediately outside their home is bordering on the insulting, particularly as there were two existing trackways they could have used if the weather was particularly inclement.

5.1“No conclusive evidence has been identified… to date the construction of the stone alignment” Dating of stone alignments is notoriously difficult. One normally relies on relationships and associations with archaeological features and structures. A line of stones leading up to a stone circle or cairn is generally accepted as proof of antiquity in the same way that the cairns on Mynydd Y Betws are accepted as prehistoric because they are in an appropriate location and look like other examples that have been dated. However, the stones forming an alignment may have been added much later and cairns could be cartloads of dumped stone. Ignoring the circumstances of its discovery for the moment the difficulty with accepting this feature as prehistoric appears to revolve around the fact that monuments of this form have not yet been identified in South Wales. The archaeological literature is filled with examples of site types being identified in previously barren areas and indeed the history of the subject has very much been involved with extending the known distribution of site types. It is possible that elements of ritual and cultural life could have made their way across the Bristol Channel. Indeed vast tracts of South West England would have been easier to get to than much of inland Wales. It should therefore not be surprising to find tangible evidence of this close geographical proximity. Travel by water in the prehistoric period from Wales to England is well attested . The report makes no mention of the possible terminal cairn or stone details which if proven would further enhance the prehistoric interpretation.

5.2“It is therefore more plausible that the current alignment is representative of a later boundary, perhaps demarcating grazing rights on the moorland, or more probably a waymarker between Bryn Mawr and the twentieth-century adit workings.” I have already presented reasons why both of these interpretations are seriously flawed on many levels. Acceptance of this conclusion in the light of these observations would require considerable justification and fresh evidence. Given that every single apparent inconsistency highlighted in the report for suggesting that the alignment is not prehistoric has been exposed as erroneous and the alternative explanations can be easily dismantled I would suggest this conclusion is invalid and should form no role in the scheduling assessment process.

The illustrations Figure 2 The area being destroyed by digger on the 16th January is depicted as having benefitted from Stage 4 archaeological works. There was no watching brief being carried out and the digger was only stopped after the DAT officer we were meeting persuaded the developers to stop. This figure is seeking to indicate that Stage 4 work was carried out in areas where it was not. The cairn to the south west of the alignment is not depicted as having had any further archaeological input and was therefore presumably destroyed without record after it was identified. Alternatively perhaps this work has been mistakenly omitted from the figure. Figure 3 Why are the two further scheduled monuments in this area not highlighted? One could suggest that this illustration which is trying to provide some sort of archaeological context for the alignment is trying to play down the prehistoric setting of the row. At the very least the omission confirms the far from rigorous character of the investigation. Interestingly nowhere within the report has any genuine attempt been made to place the alignment within its prehistoric context. Maps showing the distribution of archaeology are available on the internet, but these would not appear to have been consulted. Ignoring the available evidence where it does not fit in with your own preferred interpretation is a clear sign of blatant bias. The failure to engage with the evidence completely invalidates this report. Figures 4 & 5 This is a crude example of using imagery in a prejudiced manner. Why have two photographs from the same point been used to illustrate its character? The row is 700m long and there are many other views which would have emphasised its more typical character. There are only two on site photographs in the report and it would seem appropriate to ask the authors why they have chosen to show the same stones from the same angle. This approach really does suggest that they have something to hide since they have chosen not to illustrate the true varied character of the monument they have been asked to examine and instead have deliberately chosen to show only the length they believe illustrates their point of view. This is appalling scholarship and I would be surprised if manipulation of data in this way is acceptable professional practise.

Conclusion This report has clearly set out to disprove only the prehistoric interpretation for the stone alignment at Banc y Bryn. Despite claims that a detailed archaeological excavation has been carried out the resulting report is so tightly focussed on disproving one interpretation that it chooses to include only the evidence to support the alternative interpretations, however weak. Indeed much of the crucial evidence has been ignored or manipulated in such a way as to render this report worthless. There is no pretence at objectivity and the way in which the evidence has been sifted and discarded to suit one particular outcome is highly questionable. If Cadw choose to use the findings of this report to inform their scheduling assessment, their decision will inevitably be seriously flawed and open to challenge on many levels. In order to provide balance I have summarised the various points considered above. These are presented below.

SUMMARY OF EVIDENCE

This monument is likely to be a prehistoric stone alignment because: It is visually most similar to known prehistoric alignments in SW England Its SW to NE alignment is typical for this type of site Close association with a large number of different types of cairn The sinuous character of the row has probably resulted from variable solifluction and suggests considerable antiquity There is a probable cairn at the north east terminal. This is a common feature of SW English alignments A fallen terminal pillar at the SW end The variable size of stones used is typical of this form of alignment The recumbent stones are generally on the steeper slopes and the upright stones on the flatter ground. This situation explains the varied appearance of the alignment Socket holes would not have been necessary to hold these stones upright

This monument is unlikely to be the remnants of a fence line because: Its sinuous character is not typical for a fence line No post holes were identified in the excavation trenches No associated erosion hollow has been identified Stones were generally not laid along the entire length of a fence It has no obvious purpose

This monument is unlikely to be the remnants of a boundary bank because: No associated ditch was encountered during the excavation Other boundary banks in the vicinity survive as earthworks Many of the stones are buried suggesting depositional processes rather than erosional ones that would lead to the exposure and removal of the bank material

This monument is unlikely to be a waymarker for a path or track because: There is no logical need for a third route to the summit of Banc Bryn None of the other paths or tracks on the moor are waymarked The small size of the stones means that they are soon covered by snow There is no man made path or track on the upslope side There is no need to build a path to a small scale outcrop working whose focus would have been continually shifting

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Bronze Age ritual, funerary and settlement sites Evidence for the pre Iron-Age settlement of the study area is limited to knowledge obtained through the examination of palaeoenvironmental remains (see above) and from Bronze Age ritual and funerary monuments. These monuments – which mostly consist of round barrows/burial cairns and standing stones – are common elements in the landscape, but have a marked concentration on high ground and on the fringes of high ground. This distribution is at least in part the result of post Bronze Age, and in particular modern, agricultural practice; almost certainly there was once a more even distribution of these monuments across the study area. The presence of large numbers of these monuments, often in what is now considered to be quite remote areas, indicates a settled population in the uplands. However, evidence for contemporaneous settlements is scarce, with the best evidence provided by burnt mounds or hearths. Clearance cairns may also indicate settlement and agriculture of Bronze Age date. In some of the upland areas historic landscape components are almost entirely composed of Bronze Age ritual and funerary monuments. For a full discussion of the Bronze Age in Ceredigion see Briggs (1994).